Publication Date: 12/1/74
    Pages: 58
    Date Entered: 2/23/84
    Title: STANDARD FORMAT AND CONTENT FOR THE SPECIAL NUCLEAR MATERIAL CONTROL AND ACCOUNTING SECTION OF A SPECIAL NUCLEAR MATERIAL LICENSE APPLICATION (INCLUDING THAT FOR A URANIUM ENRICHMENT FACILITY)
    December 1974
    U.S. ATOMIC ENERGY COMMISSION
    REGULATORY GUIDE
    DIRECTORATE OF REGULATORY STANDARDS
    REGULATORY GUIDE 5.45
    STANDARD FORMAT AND CONTENT
    FOR THE SPECIAL NUCLEAR MATERIAL CONTROL
    AND ACCOUNTING SECTION OF A
    SPECIAL NUCLEAR MATERIAL LICENSE APPLICATION
    (Including that for a Uranium Enrichment Facility)INTRODUCTION
    The Atomic Energy Act of 1954, as amended, directs the U.S. Atomic
    Energy Commission (AEC) to regulate the receipt, manufacture,
    production, transfer, possession, use, import, and export of special
    nuclear material in order to protect the public health and safety and to
    provide for the common defense and security. The principal requirements
    with respect to special nuclear material licensing are found in Title
    10, Code of Federal Regulations, Part 70 (10 CFR Part 70), "Special
    Nuclear Material." Paragraph (b) of Section 70.22 of 10 CFR Part 70
    specifies that special nuclear material control and accounting
    information must be provided in a license application to show how
    compliance with the fundamental nuclear material control requirements of
    Section 70.58 of 10 CFR Part 70 will be accomplished. A special nuclear
    material control and accounting section must be prepared for the license
    application, which must be submitted prior to the beginning of
    construction. In addition to the requirements of 10 CFR Part 70,
    certain special requirements for material control and accounting would
    be included in a proposed Part 52 that is currently being prepared
    specifically for license applications for uranium enrichment plants.
    Purpose and Applicability
    This Standard Format has been prepared to provide uniformity and
    completeness in the preparation and review of the special nuclear
    material control and accounting section of license applications, to
    minimize lost time attributable to incomplete applications, and to
    standardize the licensing review process. Chapter 12 of this document
    applies to applications for construction and operation of uranium
    enrichment plants and the additional material control and accounting
    information required for such plants. In order to facilitate
    presentation of Chapter 12, it has been written as though the proposed
    Part 52 currently in preparation were in effect.
    This document is applicable to applications for licenses to
    possess at any one time and location more than one effective kilogram of
    special nuclear material and to use such material as sealed sources and
    for activities other than those involved in the operation of a nuclear
    reactor licensed pursuant to 10 CFR Part 50 and those involved in a
    waste disposal operation.
    The applicant is encouraged to prepare his application in
    accordance with the Standard Format and to provide information in each
    section to support the conclusion that he will be able to operate in
    accordance with the pertinent regulations. The information specified in
    the Standard Format is the minimum for a license application. Although
    strict conformance with the Standard Format is not mandatory,
    presentation of an equivalent level of information is necessary.
    Additional information may be required for completion of the staff
    review of a particular application. The applicant should include
    additional information, as appropriate. In this regard, it is the
    applicant's responsibility to be aware of new and revised AEC
    regulations. The information provided should be up to date with respect
    to the state of technology for the control of, measurement of, and
    accounting for special nuclear material.
    The applicant is advised to discuss his plans and programs with
    the Regulatory staff in advance of preparing his license application.
    This will allow pertinent information to be discussed with respect to
    the depth of information required for the proposed license.
    Upon receipt of an application, the Regulatory staff will perform
    a preliminary review to determine if the application provides a
    reasonably complete presentation of the information needed to form a
    basis for the findings required before issuance of a license. The
    Standard Format will be used by the staff as a guideline to identify the
    information needed. If the application does not provide a reasonably
    complete presentation of the necessary information, further review will
    be suspended until needed information is provided.
    As developments and changes in the nuclear industry occur, the
    Commission's requirements for information may need modification;
    revisions to the Standard Format will be made as necessary to
    accommodate these changes.
    Use of the Standard Format
    The applicant should follow the numbering system of the Standard
    Format at least down to the level of sections such as Section 2.4.2.
    Under some circumstances, certain sections may not be applicable to a
    specific application. This should be stated clearly, and sufficient
    information should be provided to support that conclusion.
    The applicant may wish to submit information in support of his
    application which is not required by regulations and is not essential to
    the description of the applicant's special nuclear material control and
    accounting program. This could include, for example, historical data
    submitted in demonstration of certain criteria, discussion of
    alternatives considered by the applicant, supplementary information
    regarding assumed models such as the LEMUF Models called for in Chapter
    7, or data calculations. This information should be provided as an
    appendix to the application.
    In addition, the information called for in Appendix A, "Site
    Description," to this Standard Format should be submitted as an appendix
    to the application. This information is necessary for the assessment of
    the acceptability of the applicant's material control and accounting
    plan but should not be incorporated in the special nuclear material
    license as technical specifications or license conditions.
    Upon completion of the application, the applicant should use the
    table of contents of the Standard Format as a checklist to ensure that
    each subject has been addressed.
    Style and Composition
    A table of contents should be included in each submittal.
    The application should strive for clear presentations of the
    information provided. Confusing or ambiguous statements and general
    statements of intent should be avoided. Definitions and abbreviations
    should be consistent throughout the submittal and consistent with
    generally accepted usage.
    The applicant should direct his response to the subject matter of
    each section. Wherever possible, duplication of information should be
    avoided. Thus, information already included in other sections of the
    application may be covered by specific reference to those sections.
    Where numerical values are stated, the number of significant
    figures should reflect the accuracy or precision to which the number is
    known. The use of relative values should be indicated clearly.
    Drawings, diagrams, and tables should be used where the
    information may be presented more understandably or more concisely by
    such means. These should be located with the section in which they are
    primarily referenced. Due concern should be taken to ensure that all
    information presented in drawings is legible, symbols are defined, and
    drawings are not reduced to the extent that they cannot be read by
    unaided normal eyes.
    Physical Specifications of Submittals
    All material submitted as part of the license application should
    conform to the following physical dimensions of page size, quality of
    paper and inks, and numbering of pages:
1. Paper size
    Text pages: 8-1/2 x 11 inches.
    Drawings and graphics: 8-1/2 x 11 inches preferred; however, a
    larger size is acceptable provided the finished copy, when folded, does
    not exceed 8-1/2 x 11 inches.
2. Paper stock and ink
    Suitable quality in substance, paper color, and ink density for
    handling and for reproduction by microfilming.
3. Page margins
    No less than one inch on the top, bottom, and binding side of all
    pages submitted.
4. Printing
    Composition: text pages should be single spaced.
    Type face and style: suitable for microfilming.
    Reproduction: may be mechanically or photographically reproduced.
    All pages of the text may be printed on both sides with the image
    printed head to head.
5. Binding
    Pages should be punched for looseleaf ring binding.
6. Page numbering
    Pages should be numbered by chapter and sequentially within the
    chapter, e.g., the first page of Chapter 3 would be 3-1, etc. Do not
    number the entire report sequentially.
7. Format references
    References in the application to this Standard Format should be by
    chapter, section number, and subsection number.
    Procedures for Updating or Revising Pages
    The updating or revising of data and text should be on a
    replacement page basis.
    Each changed or revised portion of a page should be highlighted by
    a vertical line. The line should be on the margin opposite the binding
    margin opposite each line changed or added. All pages submitted to
    update, revise, or add pages to the report should show the date of
    change. The transmittal letter should include an index page that lists
    the pages to be inserted and the pages to be removed. Where major
    changes or additions are made, pages for a revised Table of Contents
    should be provided.
    Number of Copies
    The licensee should submit the number of copies of each required
    submittal specified in Section 70.21 of 10 CFR Part 70 or which would be
    required in a new 10 CFR Part 52.
    Public Disclosure
    The AEC has determined that public disclosure of the details of
    special nuclear material control and accounting programs is not in the
    public interest, and withholds such details pursuant to paragraph
    2.790(d) of 10 CFR Part 2. Thus the special nuclear material control and
    accounting section of each license application should be submitted as a
    separate enclosure. Other proprietary and classified information should
    be identified clearly and submitted in separate enclosures. Each
    submission of proprietary information should be accompanied with the
    applicant's detailed reason and justification for requesting exemption
    from public disclosure as required in paragraph 2.790(b) of 10 CFR Part
    2.
    Compatibility
    The applicant should ensure that the special nuclear material
    control and accounting plan is compatible with the other sections of his
    application.
    STANDARD FORMAT AND CONTENT FOR THE SPECIAL NUCLEAR MATERIAL CONTROL AND
    ACCOUNTING SECTION OF A SPECIAL NUCLEAR MATERIAL LICENSE APPLICATION
    (Including that for a Uranium Enrichment Facility)CHAPTER 1 DESIGN OF STRUCTURES, COMPONENTS, EQUIPMENT, AND SYSTEMS
    This chapter of the application should identify, describe, and
    discuss the principal design characteristics of those structures,
    components, equipment, and systems important to special nuclear material
    control and accounting. A special nuclear material control and
    accounting section must be prepared for the license application.
    Pursuant to paragraph (f) of Section 70.21 of 10 CFR Part 70, this
    section is required to be submitted prior to the beginning of
    construction and it also would be required pursuant to provisions of a
    new 10 CFR Part 52. In general, the application submitted prior to
    construction should describe the preliminary design of the plant in
    sufficient detail to allow a definitive evaluation by the Regulatory
    staff as to whether the plant can be constructed with adequate
    provisions for the control and accounting of special nuclear material.
    The design information provided should reflect the most advanced
    state of design at the time of submission. If certain information
    identified in the Standard Format is not yet available at the time of
    submission because the design has not progressed sufficiently at the
    time of writing, the application should include the bases and criteria
    being used to develop the required information, the concepts and
    alternatives under consideration, and the schedule for completion of the
    design and submission of the missing information.
    The application should be modified prior to operation to describe
    in detail the final design of the plant, as well as operating procedures
    significant to the control and accounting of special nuclear material.
    Modifications of the design bases, criteria, or features included in the
    application submitted prior to construction, as well as any new or
    modified design bases, criteria, or features, should be identified in
    the application modifications submitted prior to operation. The
    safeguards significance of each such change should be addressed. The
    relation of the design bases to the design criteria should be described.
    1.1 Design Bases, Criteria, and Features
    In this section, discuss briefly the design bases, criteria, and
    features for the plant structures, systems, equipment, and components
    important to special nuclear material control and accounting. Identify
    and discuss, where appropriate, the relationships of special nuclear
    material control and accounting design characteristics with other design
    characteristics such as process control and health and safety. The
    design base should provide information which identifies the function to
    be performed by a structure, system, component, or pieces of equipment.
    Design criteria should establish design, fabrication, construction,
    testing, and performance requirements associated with the respective
    design bases. For each criterion, a summary should be provided to show
    how the principal design features meet the criterion. Any exceptions to
    the criteria should be identified, and the justification for each
    exception should be discussed. In the discussion of each criterion,
    reference the sections of this report where more detailed information is
    presented. The discussion in this section should include at least the
    following:
    1.1.1Material Control Areas
    Identify and explain the design characteristics that were used to
    establish the plant and internal control areas identified in Section
    4.1.
    1.1.1.1 Design Criteria for Subdivision of a Site to Improve
    Control. Present and discuss the design criteria related to special
    nuclear material control and accounting that were used to establish the
    plant and internal control areas, including such criteria as assurance
    of identifiable physical areas, capability to control special nuclear
    material by area, and capability to assign a measured value to special
    nuclear material entering or leaving an area.
    1.1.1.2 Design Features. Identify and describe the plant and
    process design features that provide for establishment of internal
    control areas identified in compliance with the design criteria
    discussed in Section 1.1.1.1, including, for example, site and plant
    layout, building structures, and equipment arrangement.
    1.1.2Automated Special Nuclear Material Control and Accounting
    Capability
    Identify those design characteristics that provide for the
    capability, if any, for automated special nuclear material control and
    accounting, including process design and layout to permit automated
    process control, automated measurement systems, and automated access
    controls.
    1.1.2.1 Design Criteria. Present and discuss the design
    criteria that were used to establish the capability for automated
    special nuclear material control and accounting, if any, including such
    criteria as timely calculation of material balances for plants and
    control areas, maintenance of current knowledge of the identity,
    location, and quantity of special nuclear material in the areas, and
    limitation of personnel access to the material and material accounting
    data.
    1.1.2.2 Design Features. Identify and describe the plant and
    process design features that provide for automated special nuclear
    material control, if any, in compliance with the criteria discussed in
    Section 1.1.2.1, including, for example, process layout, mechanization,
    and automation; storage and handling mechanization and automation; and
    in-line measurement systems.
    1.1.3Measurement Capability
    Identify those design characteristics that provide: (1) the
    capability to measure the special nuclear material content of all
    receipts, shipments, and inventories and (2) systems to assure continued
    validity of previous measurements. Such characteristics could include
    capabilities for mixing, sampling, weighing, volume determination, and
    chemical and nondestructive analyses (see also Chapter 5, Section
    5.2.2.3).
    1.1.3.1 Design Bases. Design bases for a measurement system
    should show the function of the system to provide for measurement of
    special nuclear material and the limiting contribution that the system
    is permitted to make to the total material balance uncertainty. The
    design base for any specific measurement, i.e., the total measurement at
    a specific point or the individual components of such a measurement,
    e.g., weighing, sampling, or analyzing, should show the function the
    measurement performs and the limiting contribution which that
    measurement is permitted to make to the total measurement system
    uncertainty.
    1.1.3.2 Design Criteria. Design criteria for a measurement
    system or any of its parts should show how measurements will be made and
    the limits of precision and accuracy that will permit the system and its
    parts to meet the design bases.
    1.1.3.3 Design Features. Design features should describe
    those characteristics of the measurement system and its parts that will
    permit the system to meet the design criteria. For example, weight
    measurement design features needed to meet specified precision and
    accuracy limits might be a specific type of balance located in a
    glovebox with controlled temperature and humidity. There also could be
    design features that facilitate the measurement of inprocess special
    nuclear material, including the design of process equipment, storage
    containers, transport vessels, filters, piping, and ductwork.
    1.1.4Waste Accountability
    Identify those design characteristics that provide the capability
    for the measurement of the special nuclear material content of waste
    streams prior to discard, including storage capacity to hold such
    wastes, if necessary, until they have been measured.
    1.1.4.1 Design Criteria. Present and discuss the design
    criteria that were used to establish the waste accountability systems
    for the site and the various plants or control areas within the site,
    including such criteria as assurance that the special nuclear material
    content of all waste would be measured before discard and the capability
    to assign the special nuclear material content of waste to specific
    plants or control areas.
    1.1.4.2 Design Features. Identify and describe the plant and
    process design features that provide for special nuclear material waste
    accountability in compliance with the design criteria discussed in
    Section 1.1.4.1, including, for example, mechanisms for segregating,
    holding, or measuring waste from different plants or control areas and
    mechanisms for monitoring waste streams not normally containing special
    nuclear material.
    1.1.5Scrap Control
    Identify those design characteristics that provide for control
    processing, and disposition of scrap that contains special nuclear
    material, including measurement, storage, and processing.
    1.1.5.1 Design Criteria. Present and discuss the design
    criteria that were used to establish the scrap control systems for the
    site and the various plants or control areas within the site, including
    such criteria as the capability to measure the special nuclear material
    content of the scrap, the capability to assign the special nuclear
    material content to the appropriate generating area, and the capability
    for the recovery of the special nuclear material from the scrap.
    1.1.5.2 Design Features. Identify and describe the plant and
    process design features that provide for scrap control, processing, and
    disposition in compliance with the design criteria discussed in Section
    1.1.5.1, including, for example, mechanisms for classification and
    storage of scrap from various areas, techniques and mechanisms for
    measuring the special nuclear material content of scrap, and processes
    for recovery of the special nuclear material from the scrap.
    1.1.6Special Nuclear Material Storage and Handling
    Identify those design characteristics that provide for storage and
    handling of special nuclear material so that the material is maintained
    under control at all times, including the expediting of the
    identification, inventory, and retrieval of items containing special
    nuclear material.
    1.1.6.1 Design Criteria. Present and discuss the design
    criteria that were used to establish the special nuclear material
    storage and handling system, including such criteria as assurance that
    all special nuclear material will be under control at all times,
    assuring that current knowledge of the location and quantities of
    special nuclear material is maintained, and assurance that the handling
    and storage system will provide for maintenance of special nuclear
    material measurement integrity.
    1.1.6.2 Design Features Identify and describe the site design
    features that provide for special nuclear material storage and handling
    in compliance with the design criteria identified in Section 1.1.5.1,
    including, for example, storage capacity sufficient for the special
    nuclear material to be used in each plant and control area and
    mechanisms for moving material from area to area and into or out of
    storage.
    1.1.7Design Relationships
    The design descriptions in this chapter should show the
    hierarchical relationships whereby design features are selected to
    provide structures, components, equipment, and systems meeting the
    design criteria that have been established to conform to a specific
    design base for special nuclear material control and accounting.
    CHAPTER 2 QUALITY ASSURANCE
    To provide assurance that the design, construction, and operation
    of the special nuclear material control and accounting system of a
    proposed plant are in conformance with applicable regulatory
    requirements and with the design basis and criteria specified in the
    license applications, the applicant should establish a Quality Assurance
    Program (QA Program). In this chapter of the preconstruction submission
    for a special nuclear material license, the applicant should provide a
    description of the QA Program to be established and executed for the
    material control and accounting system during the design and
    construction of the plant. In addition, prior to operation, the
    applicant should describe the QA Program to be established and executed
    for the operation of the system. The QA Program should be established
    at the earliest possible time consistent with the schedule for
    accomplishing the activity covered. Where some portions of the QA
    Program have not yet been established at the time of the preconstruction
    submission because the activity will be performed in the future, the
    description should provide a schedule for implementation. The QA
    Program should meet the requirements of Appendix B of 10 CFR Part 50
    that are applicable and appropriate to a special nuclear material
    control and accounting system.
    Where a portion of the Quality Assurance Program to be implemented
    will conform to a particular quality assurance standard, such as those
    adopted by the American National Standards Institute, the description,
    to the extent described in the standard, may consist of a statement that
    the particular standard will be followed. Where regulatory guides have
    been issued on acceptable methods of implementing portions of the
    Quality Assurance Program, the description should indicate specifically
    whether the Regulatory position of the regulatory guides will be
    followed.
    2.1 Quality Assurance During Design and Construction
    2.1.1Organization
    Organization charts for the project should be provided that denote
    the lines and areas of responsibility, authority, and communication
    within each of the major organizations involved, including those of the
    applicant, the architect-engineer, the system supplier, the constructor,
    and construction manager (if different from the constructor). In
    addition, a single overall organization chart should be included
    denoting how these companies interrelate for the specific project.
    These charts and attendant discussions should clearly indicate the
    organizational location of, organizational freedom of, and authority of
    the individual or groups assigned the responsibility for checking,
    auditing, inspecting, or otherwise verifying that an activity has been
    correctly performed. The charts and discussions should indicate the
    degree of involvement on the part of the applicant to verify the
    adequacy of implementation of the QA programs implemented by the
    applicant's contractors and suppliers, even for those cases where the
    applicant has delegated to other organizations the work of establishing
    and implementing the Quality Assurance Program or any part thereof.
    2.1.2Quality Assurance Program
    The structures, systems, and components to be covered by the QA
    Program should be identified, along with the major organizations
    participating in the program and the designated functions of these
    organizations. The written policies, procedures, or instructions which
    implement or will implement the QA Program should be described. Where
    these written policies, procedures, or instructions are not yet
    effective, a schedule for their implementation should be provided.
    2.1.3Design Control
    A description of the design control measures should be provided.
    Included should be measures to assure that appropriate quality standards
    are specified in design documents and that deviations from such
    standards are controlled; measures for the selection and review of
    suitability of application of materials parts, equipment, and processes;
    measures for the identification and control of design interfaces and for
    coordination among participating organizations; measures for verifying
    or checking adequacy of design such as by design reviews, alternative or
    simplified calculational methods, or suitable testing programs; and
    measures to assure that design changes, including field changes, will be
    subject to design control measures commensurate with those applied to
    the original design and will be reflected in accurate "as built"
    drawings and specifications.
    2.1.4Procurement Document Control
    A description of the procurement document control measures should
    be provided. Included should be measures to assure that applicable
    Regulatory requirements, design bases, and other requirements such as QA
    Program requirements which are necessary to obtain adequate quality are
    included or referenced in procurement documents.
    2.1.5Instructions, Procedures, Drawings
    A description should be provided of the measures to assure that
    activities affecting quality will be prescribed by documented
    instructions, procedures, or drawings and will be accomplished in
    accordance with these instructions, procedures, or drawings.
    2.1.6Document Control
    A description of document control measures should be provided.
    Included should be measures to assure that documents, including changes,
    are reviewed for adequacy and approved for release by authorized
    personnel and are distributed to and used at the location where the
    prescribed activity is performed.
    2.1.7Control of Purchased Material, Equipment, and Services
    A description of the measures for the control of purchased
    material, equipment, and services should be provided. Included should
    be measures for source evaluation and selection; for assessing the
    adequacy by means of objective evidence of quality furnished by the
    contractor; for inspection at the contractor source; and for examination
    of products upon delivery. A description also should be provided of the
    measures taken to assure that documentary evidence that the material and
    equipment conform to the procurement requirements is available at the
    plant site prior to installation or use of such material or equipment.
    2.1.8Identification and Control of Materials, Parts, and Components
    A description of the measures for the identification and control
    of materials, parts, and components should be provided to assure that
    incorrect or defective items will not be used.
    2.1.9Control of Special Processes
    A description of the measures for the control and accomplishment
    of special processes, if any, should be provided. Included should be a
    listing of any such special processes. The measures to assure that such
    special processes are controlled and accomplished by qualified personnel
    using qualified procedures should also be included.
    2.1.10 Inspection
    A description of the program for the inspection of activities
    affecting quality should be provided indicating specifically the items
    and activities to be covered. Included should be an organizational
    description of the individuals or groups performing inspections,
    indicating the independence of the inspection group from the group
    performing the activity being inspected, and a description of how the
    inspection program for the involved organizations has been or will be
    established.
    2.1.11 Test Control
    A description should be provided of the test program to assure
    that all testing required to demonstrate that structures, systems, and
    components will perform satisfactorily in service. Included should be
    an outline of the test program; procedures to be developed; means for
    documenting and evaluating test results of the item tested; and
    designation of the responsibility for performing the various phases of
    the program. Where a test program is used to verify the adequacy of a
    specific design feature, a description of the qualification testing of a
    prototype unit should be included.
    2.1.12 Control of Measuring and Test Equipment
    A description of the measures to assure that tools, gages,
    instruments, and other measuring and testing devices are properly
    controlled, calibrated, and adjusted at specified periods to maintain
    accuracy within necessary limits should be provided. This section does
    not refer to those devices used to measure or test the special nuclear
    material in the completed system but rather to those devices used to
    test or calibrate the system devices during installations and
    preoperational testing.
    2.1.13 Handling, Storage, and Shipping
    A description of the measures employed to control handling,
    storage, shipping, cleaning, and preservation of items in accordance
    with work and inspection instructions to prevent damage or deterioration
    should be provided.
    2.1.14 Inspection, Test, and Operating Status
    A description of the measures to indicate the inspection and test
    status of items which prevent inadvertent bypassing of such inspections
    and tests should be provided. A description should also be provided of
    the measures for indicating the operating status of the structures,
    systems, and components.
    2.1.15 Nonconforming Materials, Parts, or Components
    A description of the measures to control nonconforming materials,
    parts, or components to prevent their inadvertent use or installation
    should be provided. Included should be the means for identification,
    documentation, segregation, and disposition of nonconforming material
    and notification to affected organizations.
    2.1.16 Corrective Action
    A description of the corrective action measures established to
    assure that conditions adverse to quality are identified and corrected
    and that the cause of significant conditions adverse to quality is
    determined and corrective action taken to preclude repetition should be
    provided.
    2.1.17 Quality Assurance Records
    A description of the program for the maintenance of records to
    furnish evidence of activities affecting quality should be provided.
    Included should be means for identifying the records, retention
    requirements for the records (including duration, location, and assigned
    responsibility), and means for retrieving the records when needed.
    2.1.18 Audits
    A description of the system of audits to verify compliance with
    all aspects of the QA Program and to determine the effectiveness of the
    QA Program should be provided. Included should be means for documenting
    responsibilities and procedures for auditing, required frequency of
    audits, audit results, and the designation of management levels to which
    audit results are reported.
    2.2 Quality Assurance Program for System Operation
    The applicant should provide a description of the proposed QA
    Program that will govern the quality of the special nuclear material
    control and accounting system during operation. In addition to the
    measurement control program discussed in Chapter 6 of this format and
    the preoperational testing discussed in Chapter 5 of this format for
    each measurement system, these activities also include operating,
    maintaining, repairing, and modifying the system. The description of
    the proposed QA Program should include each of the QA criteria (Appendix
    B of 10 CFR Part 50), as outlined in Section 2.1 above.
    CHAPTER 3 ORGANIZATION
    In this chapter, describe in detail the management structure and
    the functional allocation of tasks for special nuclear material control
    and accounting. Set forth clearly the relationship of special nuclear
    material control and accounting functions to others in the licensee
    organization to denote appropriate separation of functions. Describe
    minimum qualifications for principal positions having special nuclear
    material control and accounting responsibilities to demonstrate that the
    positions will be staffed by personnel with training and experience
    commensurate with job requirements.
    3.1 Organization Structure
    In this section, describe the applicant's overall management
    structure. The organization as it will function through plant
    construction, plant calibration, and preoperational testing should be
    described in the license application submitted at the preconstruction
    stage. The organization as it will function through startup and
    operation also should be described.
    3.1.1Corporate Organization
    Identify any corporate organization positions which have
    responsibilities related to special nuclear material control and
    accounting at the site which is the subject of the application.
    3.1.1.1 Functional Descriptions. Describe the corporate level
    functions, responsibilities, and authorities for program development,
    quality assurance, calibration, testing, operations, audits, and other
    applicable activities affecting special nuclear material control and
    accounting.
    3.1.1.2 Staffing. Provide a description of the applicant's
    corporate management and technical support staffing, and in-house
    organizational relationships established to cover the functions
    identified in Section 3.1.1.1.
    3.1.1.3 Organization Charts. Furnish corporate organization
    charts showing units responsible for the functions identified in Section
    3.1.1.1. Identify lines and areas of responsibility, authority, and
    communication, the size of each unit, and the degree of subdivision or
    layers of management.
    3.1.1.4 Job Descriptions. Provide job descriptions for the
    management positions and senior staff having responsibilities for
    special nuclear material control and accounting functions, showing
    responsibilities and authority for the development, revision,
    implementation, audit, and enforcement of special nuclear material
    control and accounting programs and procedures.
    3.1.2Site Organization
    Describe the management structure for the site, emphasizing
    special nuclear material control and accounting.
    3.1.2.1 Internal Organization. By means of comprehensive
    organization charts, show the management structure of the applicant's
    facility, including the identification of all the following units, which
    have responsibilities associated with special nuclear material;
1. Overall special nuclear material control and accounting
    program direction,
2. Special nuclear material custodians,
3. Design review and control,
4. Receiving and shipping,
5. Physical inventory,
6. Measurements,
7. Statistics,
8. Construction quality assurance,
9. Production quality assurance,
10. Measurement quality assurance,
    11. Special nuclear material accounting,
    12. Analytical laboratories, and
    13. Audits.
    Show the various layers of management and the size of each unit;
    identify lines and areas of responsibility, authority, and
    communication.
    3.1.2.2 Separation of Functions. Describe the criteria
    established for the separation of special nuclear material custodial,
    measurement, accounting, and audit functions at the site so that the
    activities of one organizational unit or individual serve as controls
    over and checks on the activities of other organizational units or
    individuals. Explain how the proposed organization provides for the
    required separation of functions. Demonstrate that the control
    functions are organizationally separated from operational functions.
    3.1.2.3 Outside Support. Technical services in support of the
    applicant's special nuclear material control and accounting program may
    be provided by the use of outside consultants and technical services
    contractors. If such arrangements are to be utilized, describe the
    specific areas of responsibility and functional working arrangements of
    the support groups.
    3.2 Responsibilities and Authorities
    Utilization of special nuclear material generally results in
    involvement of numerous organizational units, each of which has specific
    duties, responsibilities, and authority. Describe the management system
    establishing, maintaining, and providing for these assignments.
    Describe the assigned duties, responsibilities, and authority of
    organization units responsible for the custody or control of special
    nuclear material. Indicate the signature authority of each
    organizational position for approving procedures and reports, including
    source data documents, for the custody, measurement, control, and
    accounting of special nuclear material.
    3.2.1Principal Special Nuclear Material Control Positions
    Describe in detail the principal organizational positions
    responsible for special nuclear material control and accounting.
    3.2.1.1 Identification of Positions. Identify the following
    positions by position titles, and reference them to the organization
    charts provided in Section 3.1.2.1:
1. Overall Program Management. The authority and
    responsibility for the overall planning, coordination, and
    administration of the special nuclear material control and accounting
    functions are required by paragraph (b)(1) of Section 70.58 of 10 CFR
    Part 70 to be assigned to a single individual at an organizational level
    sufficient to ensure independence of action and objectivity of
    decisions.
2. Measurement Control Management. Proposed amendments to 10
    CFR Part 70 would require that the overall planning, development,
    coordination, and administration of the applicant's measurement control
    program be assigned to a single individual in the organization who has
    no direct responsibilities for the operation of an analytical laboratory
    or for the processing of material. The position would be required to be
    at an organizational level sufficient to permit independence of action
    and objectivity of decision, and with authority to obtain all of the
    information required to monitor and evaluate measurement quality.
3. Accounting Management. Management of the centralized
    special nuclear material accounting system should be assigned to a
    single individual independent of all positions which have
    responsibilities for the custody of special nuclear material or for the
    generation of special nuclear material source data.
    3.2.1.2 Job Descriptions. Provide job descriptions for the
    positions identified in Section 3.2.1.1 defining the duties, authority,
    and responsibilities of each position. Indicate the minimum
    qualification requirements of each.
    3.2.1.3 Functional Relationships. Explain in detail the
    functional relationships of the above positions to others having
    responsibilities related to the custody, measurement, or control of
    special nuclear material.
    3.2.1.4 Independence of Action. Discuss the independence of
    action provided in the above positions and demonstrate that there is
    sufficient independence provided to permit objective performance of each
    position.
    3.2.2Special Nuclear Material Custodial Units
    Specify the organizational units which, in the course of their
    functions, would exercise custody over special nuclear material.
    3.2.2.1 Special Nuclear Material Custodians. Designate by
    position title, for each material balance area and item control area, a
    single individual as material custodian responsible for all special
    nuclear material within that area. Identify and explain the duties,
    responsibilities, and authority of such custodians. Submit position
    descriptions, including statements of minimum qualification
    requirements.
    3.2.3Special Nuclear Material Control and Accounting Units
    Define the duties, responsibilities, and authority of the
    organizational units identified in Section 3.1.2.1, items 3 through 12.
    To the extent appropriate, descriptions of positions should be
    submitted.
    3.2.4Audits and Reviews
    Define the duties, responsibilities, and authority of the
    organizational units which contain responsibilities for the following
    functions:
1. Review of the overall special nuclear material control and
    accounting program,
2. Audit of special nuclear material records,
3. Management and engineering reviews of the adequacy of the
    measurement control program,
4. Audit of compliance with the measurement control program,
    and
5. Review and audit of contractors' measurement control
    programs, if applicable.
    3.2.5Delegation of Authority
    Describe the program established for the written delegation of
    authority and responsibility for the special nuclear material control
    and accounting function.
    3.3 Training Programs
    Implementation of the applicant's special nuclear material control
    and accounting program requires the assignment of personnel having
    experience and training consistent with the duties, authorities, and
    responsibilities of their respective positions. Describe the training
    programs to be established to provide the original cadre of qualified
    personnel and to provide for the maintenance of the qualifications of
    personnel assigned to special nuclear material control and accounting
    functions. Affirm that training procedures and qualification criteria
    will be established.
    CHAPTER 4 MATERIAL CONTROL AREAS
    In this chapter, describe the division of a site and plants within
    a site into material balance areas (MBAs) and item control areas (ICAs).
    The division of a large complex site into smaller material control areas
    can improve special nuclear material control and accounting in several
    ways. A number of plant and internal control areas within plants may be
    required to facilitate the assignment of responsibility and
    accountability, to effect an internal control system of checks and
    balances, to lower thresholds for detecting losses, and to localize
    material losses. Regulatory Guide 5.26, "Selection of Material Balance
    Areas and Item Control Areas," discusses the advantages of such
    subdivision and describes bases for the selection of the MBAs and ICAs.
    4.1 Identification of Control Areas
    In this section, identify and describe the subdivision of the site
    into plants, material balance areas, and item control areas.
    4.1.1Plant Areas
    By reference to the site description and the process flow diagrams
    provided in Appendix A, and by other suitable means, identify the title,
    location, and boundaries of each designated plant. For special nuclear
    material control and accounting purposes, a plant is defined as a set of
    processes or operations coordinated into a single manufacturing, R&D, or
    testing effort. A small site may contain only a single plant in this
    context. A scrap recovery operation servicing offsite customers or more
    than one plant should be treated as a separate plant. Discuss the
    principal parameters that were considered in the selection of plant
    areas, including physical, technical, process, and administrative
    considerations.
    4.1.2Internal Control Areas
    By reference to the site description and the process flow diagrams
    provided in Appendix A and other suitable means, identify the
    designation, location, and boundaries of each MBA and ICA. Care must be
    taken to assure that there is no overlap.
    4.1.2.1 Process Boundaries. Describe the process boundaries,
    including identification of the processes and unit operations that are
    included in each control area. Identify all process flows entering and
    leaving the control areas, including main process, scrap, waste, and
    recycle flows and intermediate storage.
    4.1.2.2 Physical Boundaries. Describe the physical
    boundaries, including identification of the actual physical barriers
    that exist around and between control areas. Such barrier
    identification could be a building name or number, room numbers within a
    building, or diagrams showing walls or grids dividing a process area or
    room into control areas. Identify access points in the physical
    boundaries for all material flows.
    4.1.2.3 Selection Criteria. Discuss the principal parameters
    that were considered in the selection of each control area. Present an
    analysis of the loss or theft detection capability of each MBA, along
    with analyses to show how the selected control areas provide for
    localization of losses or thefts of special nuclear material and for
    identification of the mechanism for any such loss or theft.
    CHAPTER 5 MEASUREMENTS
    In this chapter, identify and describe the various measurements
    that are to be used in special nuclear material control and accounting.
    Describe the measurement procedures and equipment involved in each
    measurement, including an explanation of how the equipment is used to
    make the measurement. Include statements of the measurement
    uncertainties expected for the various measurements.
    5.1 General Description
    In this section, provide a general description of the measurement
    system for each plant.
    5.1.1Measurement Points
    On a plant basis, identify each point where measurements are made
    for purposes of special nuclear material control and accounting. Refer
    to the flow diagrams provided in Appendix A, as appropriate.
    5.1.2Materials and Measurements
    Characterize the materials and measurements for each measurement
    point. One suitable means of presentation would be a coded chart showing
    the types of materials and the components of measurement involved at
    each measurement point (weight, volume, sampling, analytical assay, or
    nondestructive assay).
    5.2 through 5.6Detailed Measurement Systems
    In Sections 5.2 through 5.6, describe in detail each of the
    measurements and measurement systems to be used at the site for special
    nuclear material control and accounting. A separate section should be
    devoted to each type of measurement system as follows:
    5.2 Mass Measurements
    5.3 Volume Measurements
    5.4 Sampling Systems
    5.5 Analytical Measurements
    5.6 Nondestructive Assay Measurements
    5.n Others, as appropriate
    Each of these sections should be structured to present information
    using the following subsections.
    5.2(*).1 Systems Identification
    Identify all of the measurement systems of a specific type to be
    used at the site for special nuclear material control and accounting.
    Relate each measurement system to the measurement points identified in
    Section 5.1.
    5.2(*).2 Measurement Systems
    Discuss each measurement system of the specific type identified in
    Subsection 5.2(*).1 above in sequential order (e.g., 5.2.1, 5.2.2,
    5.2.3, 5.2.4, etc.) using the following subtopics.
    5.2(*).2.1General Characteristics. Describe each measurement
    system, including descriptions of the principal equipment involved and
    sampling or measurement methods and techniques used. Refer to drawings,
    diagrams, and documents, as appropriate.
    5.2(*).2.2Rationale. Discuss the rationale for selection of the
    described measurement system.
    5.2(*).2.3Design. Describe the design bases, criteria, and
    features of each system that ensure the ability to provide reliable,
    precise, and accurate measurements. Identification and discussion of
    design considerations for the various types of measurements systems
    should include the assumptions made in developing design bases and
    criteria, including statements of the expected random and systematic
    errors used as design criteria. Discussion of design features should
    include information regarding such items as environmental controls
    required for specific measurements or measurement systems, modifications
    to standard designs that might have been made, and assumptions or
    criteria regarding linear operating regions for volume measurement
    systems or nondestructive assay systems (see also Chapter 1, Section
    1.1.3).
    5.2(*).2.4Preoperational Testing. Discuss the preoperational
    tests and evaluations that will be performed before each measurement
    system is committed to special nuclear material measurements. List the
    criteria that will be used for qualifying each system.
    The completed presentation for Sections 5.2 through 5.6 should
    follow the following format:
    5.2 Mass Measurements
    5.2.1Mass Measurement Systems Identification
    5.2.2Mass Measurement No. 1
    5.2.2.1 General Characteristics
    5.2.2.2 Rationale
    5.2.2.3 Design
    5.2.2.4 Preoperational Testing
    ----------
    (*) Numbered 2 through 6 for the respective types of measurement
    systems.
    ----------
    5.2.3Mass Measurement No. 2
    5.2.3.1 General Characteristics
    5.2.3.2 Rationale
    5.2.3.3 Design
    5.2.3.4 Preoperational Testing
    5.2.4Mass Measurement No. 3 etc. for each mass measurement.
    5.3 Volume Measurements
    5.3.1Volume Measurement Systems Identification
    5.3.2Volume Measurement No. 1
    5.3.2.1 General Characteristics
    5.3.2.2 Rationale
    5.3.2.3 Design
    5.3.2.4 Preoperational Testing
    5.3.3etc. for each volume measurement.
    5.4 Sampling Systems
    5.5 Analytical Measurements
    5.6 Nondestructive Assay Measurements
    Additional sections may be added, as appropriate.
    5.7 Measurement Uncertainties
    In this section, list, by plant, the expected measurement
    uncertainties of the described measurement systems. For each
    measurement point and type of material identified in Section 5.1, state
    the expected random and systematic errors of each component of
    measurement (weight, volume, sampling, analytical assay, or
    nondestructive assay) on the basis of a single determination. The
    confidence levels at which, and units in which, the errors are expressed
    should be identified clearly.
    5.8 Measurement Procedures
    Affirm that a special nuclear material measurements procedures
    manual will be established and maintained. Identify the organizational
    units responsible for the preparation, modification, and approval of
    measurement procedures and the periodic review of the procedures manual.
    CHAPTER 6 MEASUREMENT CONTROL PROGRAM
    An ongoing quality assurance program for special nuclear material
    measurements is required by paragraph (f) of section 70.58 of 10 CFR
    Part 70 to control measurement performance and to provide current data
    for the determination of measurement uncertainties. In this chapter,
    provide a detailed description of the measurement Quality Assurance
    Program. If contractors are to be used to provide measurement services,
    their measurement Quality Assurance Programs should be described and
    assurance provided that an acceptable level of measurement control will
    be maintained.
    6.1 Organization and Management
    This section should describe the organizational relationship,
    showing in particular how the special nuclear material measurement
    quality assurance function is assigned so that it is independent of the
    analytical laboratory and operating departments and is at a level to
    assure objectivity and independence of action.
    6.1.1Functional Assignment
    In this section, show how the position assigned responsibility for
    the measurement Quality Assurance Program is related to the positions
    responsible for the analytical laboratory or other functions responsible
    for processing and measuring special nuclear material. Show the
    relative management level at which the measurement quality assurance
    function is assigned. Personnel qualifications for the measurement
    quality assurance function also should be set forth.
    6.1.2Procedures
    Affirm that a special nuclear material measurements quality
    assurance manual will be established and maintained. Identify the
    organizational units responsible for the preparation, modification, and
    approval of measurement quality assurance procedures and the periodic
    review of the manual.
    6.1.3Management Review
    Describe the program established for the conduct of an annual
    management review of the measurement quality assurance program.
    6.1.4Internal Audits
    Describe the auditing program established to determine compliance
    with the measurement quality assurance procedures. Indicate the
    frequency for conducting program audits.
    6.1.5Contractor Program Audit
    If measurement services are provided by an outside contractor or
    another company laboratory, describe the audit program established to
    monitor such offsite performance. Specify the frequency of such audits.
    6.2 Calibration and Standards
    Accurate measurement of special nuclear material requires a system
    of standards and calibrations for the determination of bias and
    systematic errors for all special nuclear materials measurements,
    including mass, volume, analytical, and nondestructive measurements.
    6.2.1Reference Standards
    Identify and describe the use and control of each type of
    reference standard used in this measurement calibration program.
    6.2.1.1 Listing. Provide a list of all the standards to be
    used in this measurement program, including mass, volume, analytical,
    and nondestructive testing standards.
    6.2.1.2 Certification. Identify the source of and describe
    the certification plan for each standard, including the frequency of
    certification and recertification. Discuss the bases for selection of
    the recertification intervals.
    6.2.1.3 Traceability. Indicate the traceability of each
    standard to the national system of measurements and standards or to a
    natural physical constant.
    6.2.1.4 Representativeness. Discuss the representativeness of
    each standard with respect to the measurement system in which it will be
    used.
    6.2.1.5 Controls. Explain the controls to be employed to
    ensure continued validity of the standard values, e.g., environmental
    controls such as storage in controlled atmosphere or use controls such
    as use only by designated personnel.
    6.2.2Standard Measurements
    Describe the program for standard measurements to be made during a
    material balance interval for each measurement system. The description
    should include:
1. The minimum number of standard measurements for each
    material balance interval,
2. The schedule for the standard measurements,
3. The basis for the schedule,
4. The approximate number of technicians associated with the
    standard measurements, and
5. Explanation of how the standard measurements will be
    performed so that they will be representative of routine
    measurement performance.
    6.2.3Calibration Systems
    Describe the calibration method to be used for each measurement
    system.
    The descriptions should include:
1. The minimum number of calibration runs for the initial
    calibration,
2. The range of the calibration, its adequacy and basis for
    selection,
3. Identification of the standards to be used, with references
    to Section 6.2.1, as appropriate,
4. The schedule for recalibration, including the minimum
    frequency, and
5. The criteria to be used to determine the need for
    recalibration.
    6.2.4Statistics
    Discuss how the standard measurements data and calibration data
    will be used to determine measurement biases and systematic errors, and
    the measurement errors of calibration. Describe the procedures to be
    used to make bias corrections. Describe the basic statistical
    methodology and techniques to be used.
    6.3 Sampling Accuracy
    Establishment of accurate and representative sampling procedures
    requires that process and engineering studies be performed to establish
    procedures for mixing and sampling bulk materials and for maintaining
    sample integrity during transport and storage. In this section,
    describe such process and engineering studies for each measurement
    system, as appropriate, including procedures for monitoring the
    continued accuracy of the systems. Refer to preoperational testing
    procedures given in Section 5.4.2.4, as appropriate.
    Any use of standards in such studies also should be discussed.
    Describe how the results of such studies will be used to determine
    sampling accuracy, including the statistical methodology and techniques
    used.
    6.4 Measurement Precision
    The determination of random errors in sampling and measurements
    requires that the measurement quality assurance program include a system
    of control measurements that provide current data on which to base the
    determination.
    6.4.1Program Description
    Describe the program or replicate sampling and measurements to be
    used for the determination of random errors for each measurement system.
    The descriptions should include:
1. Procedures for replicate sampling and analysis of process
    materials.
2. Procedures for replicate weight and volume measurements,
3. The minimum number of replicate samples and replicate
    measurements to be performed during a material balance
    interval,
4. The predetermined schedules on which the replications will
    be performed,
5. The basis for the schedules, including an analysis of their
    adequacy in relation to the limit of error requirements in
    section 70.51 of 10 CFR Part 70, and
6. Description of how the program will provide for the
    determination of between-operator, between-equipment, and
    between-shift variances, as appropriate.
    6.4.2Statistics
    Describe how the replicate data will be used to determine random
    errors of sampling and measurements, including the basic statistical
    methodology and techniques used.
    6.5 Control Program
    A reliable measurement system requires that a system of
    statistical tests or control charts be established and maintained to
    control measurement biases and errors within predetermined limits.
    6.5.1Basic Program
    Describe the basic program to be established to monitor and
    control sampling and measurement performance. Identify and explain the
    system of statistical tests or control charts to be employed.
    6.5.2Control Limits
    Explain how control limits for the statistical tests or control
    charts described above will be established and periodically updated,
    including the frequency with which current control data will be
    evaluated for updating control limits. Discuss the rationale and
    statistical bases for the system to be used. By position titles listed
    in Section 3.1.1, indicate the persons who have the authority for
    approving control limits.
    6.5.3Control Response
    Describe the plan of action to be implemented when sampling or
    measurement performance falls outside of control limits, including
    procedures to assure that out-of-control measurement systems will not be
    used to generate materials accounting source data.
    6.6 Records and Reports
    In this section, provide a detailed description of the records and
    reports that will be established for the measurements quality assurance
    program, including records of measurement data generated in measurement
    calibration and testing programs, summaries of error data used in the
    limit of error calculations performed for each material balance period,
    statistical control records, and reports of corrective action taken as a
    result of system deficiencies.
    CHAPTER 7 LIMITS OF ERROR
    Section 70.51 of 10 CFR Part 70 requires establishment and
    maintenance of a system of measurements such that the limits of error
    for any MUF (LEMUF) do not exceed the values specified in paragraph
    70.51(e)(5) of 10 CFR Part 70 or other limits authorized by the
    Commission pursuant to paragraph 70.51(e)(6), 10 CFR Part 70. In this
    chapter, summarize the capabilities of each measurement system to
    achieve the specified control limits. If the applicant cannot meet the
    specified limits for a plant, he should request higher limits in
    accordance with the provisions of paragraph 70.51(e)(6), 10 CFR Part 70.
    7.1 LEMUF Models
    In this section, submit error models for each individual material
    balance area and for each plant material balance to demonstrate the
    capability for obtaining an acceptable LEMUF. For each enrichment
    category of enriched uranium, separate models should be prepared for the
    element and for U-235; models for plutonium should be for the element
    only. These models should be submitted as an appendix to the
    application so that the models do not become license conditions. The
    application should include a summary statement based on the models
    showing how the respective plants will be operated in compliance with
    the LEMUF requirements in the regulations.
    7.1.1Material Quantities
    Provide, on a plant basis, a listing of the typical flow
    quantities for special nuclear material during a material balance
    period, including the batch size and number of batches for each type of
    material. Refer to Section 5.1.2, as appropriate.
    7.1.2Samples and Analyses
    State the typical number of samples that will be taken and the
    typical number of replicate analyses per sample that will be performed
    for each batch and type of material, as applicable. Refer to Sections
    5.4 and 5.5, as appropriate.
    7.1.3Error Propagation
    Describe the statistical methodology and techniques used for
    combining random and systematic error for material flow and inventory
    quantities to obtain limits of error for material balances, i.e., LEMUF.
    Discuss specifically how measurement covariances are treated and
    accounted for.
    7.1.4Modeling
    The random and systematic errors from Section 5.7, the inventory
    quantities from Section 8.2, the material flow quantities from Section
    8.2, the material flow quantities from Section 7.1.1, and the sample and
    analysis data from Section 7.1.2 should be combined, using the formula
    given in Section 7.1.3 to produce the required LEMUF models. Show all
    assumptions and calculations.
    7.2 Requests for Higher LEMUF Limits
    This section should be used to request higher limits for plant
    LEMUF values than those specified in paragraph 70.51(e)(5), 10 CFR Part
    70. Pursuant to paragraph 70.51(e)(6), 10 CFR Part 70, the applicant is
    required to justify requests for higher limits for LEMUF and describe
    the program of improvement that will be initiated to meet the plant
    LEMUF limits of paragraph 70.51(e)(5), 10 CFR Part 70, at a later date.
    7.2.1Request
    The applicant should state the requested higher limits for LEMUF
    and should provide the appropriate justification in this section.
    7.2.1.1 Higher Limits. Submit the request for higher LEMUF
    limits on an individual plant basis.
    7.2.1.2 Limitations. Identify and discuss the limitations
    that prevent attainment of the plant LEMUF limits specified in paragraph
    70.51(e)(5), 10 CFR Part 70.
    7.2.1.3 Rationale. Describe the rationale for selecting the
    LEMUF limits stated in Section 7.2.1.1 above.
    7.2.2Bases for Consideration
    The applicant should use this section to provide information that
    will be useful in the consideration of the requested higher LEMUF
    limits.
    7.2.2.1 Alternatives. Discuss process and measurement
    alternatives for minimizing each plant LEMUF limit within current
    measurement capabilities. Provide a cost/benefit analysis, as
    appropriate.
    7.2.2.2 Improvement Program. Describe the program of
    improvement that will be implemented pursuant to paragraph 70.51(e)(6),
    10 CFR Part 70. Delineate and discuss the specific actions that will be
    taken in the improvement program. Provide time schedules for
    implementation of the improvement program.
    CHAPTER 8 PHYSICAL INVENTORY
    Physical inventories are performed periodically to calculate a
    material balance for a given accounting interval and to adjust the
    accounting records to the physical inventory quantities. Section 70.51
    of 10 CFR Part 70 requires that physical inventories be based on
    measurements and specifies intervals for various material types.
    Regulatory Guide 5.13, "Conduct of Nuclear Material Physical
    Inventories," discusses acceptable methods and techniques for conducting
    special nuclear material inventories. In this chapter, describe the
    physical inventory program for special nuclear material.
    8.1 General Description
    In this section, provide a general description of how a physical
    inventory is planned and conducted.
    8.1.1Basic Approach
    Explain the basic inventory approach utilized at each of the
    plants. The information should include the types of physical
    inventories typically planned for material in process, including the
    extent of plant or process shutdown and cleanout. Should the applicant
    plan to perform portions of the physical inventory while process
    material is in a dynamic state, the information should include the
    extent to which the inventory would use such techniques as Process
    Blank, Tracer or Step Function, Counter-Current, or Process Parameter
    techniques as described in Regulatory Guide 5.13.
    Cleanout inventories normally are required for the authorization
    of higher LEMUF limits granted pursuant to paragraph 70.51(e)(6), 10 CFR
    Part 70. The applicant should provide inventory details based on
    cleanout for those plants for which a higher limit is requested.
    8.1.2Schedules
    Specify the physical inventory schedule for each plant. Discuss,
    as supporting information, any special considerations which affect the
    selection of inventory schedules.
    8.1.3Organization
    Explain the makeup and duties of the typical physical inventory
    organization. Identify who would have the responsibility for the
    coordination of the physical inventory effort.
    8.1.4Procedures
    Indicate how the preparation and modification of inventory
    procedures are to be controlled. Identify, by positions in the
    organization, the personnel who would have responsibility for the
    preparation and modification of inventory procedures. Affirm that
    specific inventory instructions will be prepared for each physical
    inventory.
    8.1.5Source Data
    Describe how source data will be originated and retained on record
    to ensure that all items on inventory can be traced to measurements.
    8.1.6Forms Control
    Discuss the controls to be exercised over the distribution and use
    of inventory forms.
    8.2 Typical Inventory Composition
    In this section, submit information describing a typical physical
    inventory for each material control area and plant. The information
    should include listings of typical quantities (including batch size) and
    types of materials expected to be in each MBA, in process, under
    tamper-indicating procedures, and as unopened receipts or as ultimate
    product. The listings should show the magnitude of the random and
    systematic errors expected to be associated with each line item.
    8.3 Inventory Preparation
    In this section, describe the detailed preparations that will be
    made for the taking of physical inventories.
    8.3.1Prelisting of Inventory
    Describe programs, if any, that would provide for the prelisting
    of inventory, including practices for locating, identifying, and listing
    all items on inventory, including sealed sources.
    8.3.2Inventory Tags
    Describe the use of inventory tags or other mechanism to
    facilitate accurate listing of inventory.
    8.3.3Cutoff Procedures
    Describe the cutoff procedures to be used for processing and
    transferring special nuclear material and for the material records to
    ensure an accurate recording of material transactions and inventory
    items. Explain the controls to be exercised over the movement of
    material into and out of material control areas during the time of
    inventory.
    8.3.4Special Processing
    Identify and discuss plans for the processing of material to
    specific physical forms and measurement locations preferred for
    inventory taking.
    8.3.5Inventory Reduction
    Explain any plans for the reduction of plant inventories at times
    of physical inventory.
    8.3.6Cleanout
    Describe in detail any plans for the draindown or cleanout of
    inventory from processing areas in preparation for physical inventories.
    8.4 Conduct of Inventory
    In this section, discuss the detailed plans for conducting a
    physical inventory.
    8.4.1Item Inventories
    Provide details on how items are to be inventoried, including
    procedures for assuring that no item is listed more than once and none
    are omitted. Indicate whether items are to be inventoried by
    identification or piece counting. Describe the use of tamper-safing, as
    appropriate, for the inventory of the special nuclear material content
    of items.
    8.4.2Current Measurements
    Provide a detailed listing of typical measurement points for a
    physical inventory and descriptions or references to the measurement
    methods to be used, including the use of calibrated vessels and
    equipment and nondestructive assay methods, as appropriate.
    8.4.3Prior Measurements
    Indicate the bases for acceptance of prior measurements for
    physical inventory, including a description of the application of
    tamper-safing techniques. Provide a detailed listing of locations
    where, typically, material will be inventoried on a prior measurement
    basis.
    8.4.4Use of Factors
    State the bases for the use of inventory factors. Explain how the
    factors are to be developed and controlled on the basis of measurements.
    8.4.5Residual Holdup
    Characterize the residual holdup of material in processing lines,
    tank heels, equipment, hoods, and ventilation ducts. Describe how these
    materials are to be inventoried or determined to be insignificant.
    8.4.6Post-Inventory Inspection
    Describe procedures that are to be used for the followup
    inspection of inventory areas to assure that all materials in the area
    have been inventoried, including cutoff verification and list and tag
    checks.
    CHAPTER 9 MATERIAL ACCOUNTING SYSTEM
    Paragraph (k) of Section 70.58 of 10 CFR Part 70 requires
    licensees to maintain a system of records and reports that will provide
    information sufficient to locate special nuclear material and to
    calculate a measured material balance around each material balance area
    and the total plant. To meet the material balance requirements of
    Section 70.51 of 10 CFR Part 70, the accounting for uranium must be on
    the basis of element and fissile isotope, with separate accounts for
    each enrichment category. Accounting for plutonium is required for the
    element only. In this chapter, describe the special nuclear material
    accounting system, including the associated reporting system.
    9.1 System Description
    In this section, describe the details of the basic special nuclear
    material accounting system. A centralized accounting system employing
    double-entry bookkeeping must be established and maintained. Subsidiary
    accounts must be established for each material balance area and item
    control area.
    9.1.1Account Structure
    Describe the double-entry records system in terms of the general
    and subsidiary ledgers and journals, together with a chart of accounts.
    Identify and describe the records which will be maintained of additions
    to and removals from the process and of the quantities of material in
    unopened receipts and ultimate product maintained under tamper-safing or
    in the form of sealed sources.
    9.1.1.1 Accounting Forms. Identify and describe the basic
    accounting forms that will be used for recording and transmitting
    accounting data, including source data.
    9.1.1.2 Flow Chart. Provide a flow chart of the records and
    documents used for special nuclear material accounting, including: (1)
    the physical flow of documents, (2) the posting points, and (3) the data
    retention points.
    9.1.2Accounting Procedures
    Affirm that an accounting procedure manual will be established and
    maintained. Identify, by position titles, those individuals who have
    responsibility for the initial preparation and the periodic updating of
    the manual. Indicate what approvals are required.
    9.1.3Source Data
    Define the specific source data that will be used as the basis of
    original entry to the accounting records. Such information should cover
    external receipts and shipments, internal transfers between MBAs and
    ICAs, waste or scrap transfers or removal, inventories, and adjustments
    to any of these.
    9.1.4Adjustments to Records
    Describe the methods whereby adjustments to prior recorded values
    are made, including the forms or records used and the approvals
    necessary.
    9.1.4.1 Bias Adjustments. Explain how bias adjustments for
    measurements are incorporated into the accounting system.
    9.1.5Inventory Reconciliation
    Describe the accounting methods for reconciling the accounting
    records to physical inventory quantities, including the records used and
    the approvals required. Provide a flow chart of the adjustment
    proceedings.
    9.1.6Account Reconciliation
    Describe the procedures for and frequency of reconciliation of
    subsidiary accounts with control accounts, including the approvals
    required for adjustments and responsibilities for making the
    reconciliations and adjustments. Should the chart of accounts be set up
    by project, or any designation other than by MBA/ICA, discuss how the
    project accounts will be closed to MBA/ICA and plant accounts.
    9.1.7Location and Identity Records
    Describe the records and reports used to provide information
    relative to the identity and location of special nuclear material items.
    Explain the interface of this system with the material accounting
    system, if any. Identify by position titles those individuals
    responsible for the various parts of this system.
    9.1.8Electronic Data Processing
    Define the extent, if any, to which special nuclear material
    reports, accounts, or inventory data are processed by electronic data
    processing systems. As appropriate, describe the design bases and
    features covering the installation of electronic data processing
    capabilities. Outline the preoperational testing that will be
    performed.
    9.2 Records and Reports
    In this section, identify and describe the reports that will be
    generated by the accounting system for the reporting and control of
    special nuclear material. The short-term and long-term storage of
    records and reports also should be discussed.
    9.2.1Accounting Reports
    Provide a listing and description of the reports that will be
    generated by the special nuclear material accounting system. Explain
    the data bases for the preparation of each report.
    9.2.1.1 Material Balance Reports. Affirm that material
    balance reports containing all the information required in paragraph
    70.51(e)(4), 10 CFR Part 70, shall be completed within 30 calendar days
    after the start of each ending inventory required by paragraph
    70.51(e)(3), 10 CFR Part 70.
    9.2.1.2 Material Status Reports. Affirm that material status
    reports will be submitted in accordance with the requirements of Section
    70.53, 10 CFR Part 70.
    9.2.2Accounting Records
    Identify by title the accounting documents that will be retained
    as a part of the accounting record, including source data documents.
    9.2.3Short-Term Storage
    Describe the short-term disposition and storage of all special
    nuclear material accounting documents, forms, and reports, including
    source data documents. Explain the physical and administrative controls
    that will be implemented to limit access to and protect the integrity of
    these records.
    9.2.4Long-Term Storage
    In this section, describe the storage system that will be utilized
    for the long-term retention of the records required by paragraphs (e)(4)
    (iii), (iv), and (v) of Section 70.51, 10 CFR Part 70. Specify the
    physical form in which the material balance records will be kept.
    Describe the file system for the stored documents. Discuss the system
    of access control.
    9.3 Audits
    In this section, describe the auditing program for the special
    nuclear material accounting system. Specify the frequency for regular
    audits and describe the documentation that will be prepared and kept
    available at the site for inspection for a period of five years.
    CHAPTER 10 INTERNAL CONTROL
    In this chapter, discuss the internal control practices for
    special nuclear material. Procedures used in receiving, storing,
    transferring, and shipping of special nuclear material should be
    described.
    10.1 Material Receipt
    In this section, describe the control procedures established for
    the receipt and verification of offsite shipments of special nuclear
    material.
    10.1.1 Receiving Procedure
    Present a summary description of how materials are received,
    stored, and measured. Discuss the technical justification for each
    sampling plan.
    10.1.2 Shipper-Receiver Comparisons
    Identify and describe the shipper-receiver comparisons that are
    made to verify the identification and the quantity of special nuclear
    material received, including packaging, labeling, item count,
    measurement, and document checks.
    10.1.3 Acceptance Criteria
    List the criteria for accepting special nuclear material on both
    an item or batch, and total shipment basis, including the statistical
    technique used for evaluating shipper-receiver differences by individual
    shipment, shipment series, and individual lot or container.
    10.1.4 Conditions for Transfer
    Describe the conditions for releasing special nuclear material to
    operating components.
    10.1.5 Records
    Discuss the records that are kept of shipper-receiver comparisons,
    evaluations, and investigations. Affirm that shipper-receiver records
    are kept on file for a period of at least five years.
    10.2 Internal Transfers
    In this section, provide a general description of the internal
    control procedures for the transfer of special nuclear material within
    the site. Describe the documentation and signature requirements.
    10.2.1 Timeliness
    Describe the controls exercised to assure that original source
    data documents are executed at the time special nuclear material passes
    to or from an MBA or an ICA, and that such data are entered promptly and
    accurately into the records system.
    10.3 Storage and Item Control
    Discuss the system of storage and internal handling controls
    established to provide current knowledge of the identity, quantity, and
    location of all special nuclear material contained within a site in
    discrete items and containers
    10.3.1 Program Coverage
    Identify all of the types of items and containers that will be
    covered by this program. Explain any exclusions.
    10.3.2 Identification
    Explain how the controlled items are to be uniquely identified.
    10.3.3 Quantity Determination
    For each type of item, explain how the quantity determination will
    be made.
    10.3.4 Records
    Describe the inventory records that will be utilized for recording
    the identity, location, and quantity of special nuclear material on
    inventory. Explain what records will be employed for recording the
    source and disposition of all items.
    10.4 Tamper-Safing Program
    If applicable, describe in this section the program to be followed
    for establishing and maintaining tamper-indicating devices applicable to
    containers and vaults containing special nuclear materials.
    10.4.1 Types of Devices
    Provide a listing and description of the types of devices used for
    vaults and for the various types of containers. Design information
    should be submitted, as appropriate. For pressure-sensitive seals, the
    criteria listed in Regulatory Guide 5.10 should be addressed. Submit
    two samples of each type of seal with the application.
    10.4.2 Indicating Features
    Describe the tamper-indicating features of the devices listed in
    Section 10.4.1 above.
    10.4.3 Application
    Indicate how each type of device is to be applied to assure the
    protection of the various types of containers and vaults.
    10.4.4 Identification
    Describe the identification system to be used for the
    tamper-indicating devices.
    10.4.5 Access
    Discuss the plan to be used for limiting personnel access to the
    devices prior to issuance.
    10.4.6 Control
    Describe the procedures to be used in the issuance, application,
    and disposal of the tamper-indicating devices. Discuss how the control
    officer assures that the devices are properly applied, including the
    recording of time and location.
    10.4.7 Records System
    Describe the records system to be used for the control and
    application of the tamper-indicating devices.
    10.4.8 Monitoring Program
    Explain the monitoring program for periodically verifying the
    presence and integrity of tamper-indicating devices in use.
    10.4.9 Response
    State the plan of action to be followed when it has been
    determined that the integrity of a tamper-indicating device has been
    compromised.
    10.5 Scrap and Waste Control
    In this section, discuss the program for the control, processing,
    and disposition of scrap and waste.
    10.5.1 Location
    Identify the scrap and waste quantities of contained special
    nuclear material with respect to source, storage, and disposition.
    Refer to process flow charts and plant operations descriptions.
    Identify storage areas and capacities for scrap and waste.
    10.5.2 Processing and Storage
    Estimate the rate of generation of scrap and waste for each plant
    under startup and normal processing conditions. Estimate the rate of
    recovery of scrap, and indicate the average amount of special nuclear
    material in the form of scrap expected to be in storage at any given
    time. Describe any programs for offsite shipment and recovery of scrap,
    as appropriate. Describe procedures for the control and discard of
    wastes containing special nuclear material, including procedures and
    capabilities for storage prior to discard.
    10.5.3 Measurement
    Describe the procedures for determining the special nuclear
    material content of scrap and waste, including the criteria and
    procedures for segregation, identification, and classification of
    various kinds of scrap to facilitate measurement and procedures used to
    monitor waste streams not normally expected to contain special nuclear
    material. Identify quantities of scrap that will have measurement
    uncertainty of greater than @@10% (limit of error). Refer to the
    appropriate parts of Chapter 5.
    10.5.4 Inventory Control
    Describe the control program that will be implemented to limit the
    accumulation of scrap so that no item of scrap generated in the
    licensee's plant measured with an uncertainty of greater than @@10
    percent remains on inventory longer than six months when such scrap
    contains plutonium (except plutonium containing 80 percent or more by
    weight of the isotope Pu-238), U-233, or uranium enriched 20 percent or
    more in the isotope U-235 or longer than twelve months when such scrap
    contains uranium enriched less than 20 percent in the isotope U-235 or
    plutonium containing 80 percent or more by weight of the isotope Pu-238.
    10.6 Shipping
    In this section, describe the control procedures established for
    the offsite shipment of special nuclear material.
    10.6.1 Internal Transfer
    Indicate the type of measurement data and tamper-safing
    information provided to the group responsible for making special nuclear
    material shipments.
    10.6.2 Overchecks
    Describe the type of overchecks, including any measurements, that
    are made by the shipping group.
    10.6.3 Records
    Discuss the types of records maintained by the shipping group.
    CHAPTER 11MANAGEMENT
    Paragraph (c) of Section 70.58 of 10 CFR Part 70 requires that
    licensees establish, maintain, and follow a management system to provide
    for the development, revision, implementation, and enforcement of
    special nuclear material accounting procedures. In this chapter,
    describe the management system to be used to comply with this
    requirement.
    11.1 Procedures
    In this section, describe the management system which provides for
    written approval of special nuclear material control and accounting
    procedures and any revisions thereto, including identification, by
    position title, of the individual responsible for preparing and
    approving such procedures.
    11.2 Enforcement
    In this section, describe the management systems used to assure
    compliance with the approved facility procedures and government
    regulations.
    11.2.1 Management Review
    Describe the scope, extent, and frequency of the management review
    of the conduct of the special nuclear material control and accounting
    program, including identification, by position title, of the individuals
    who will be responsible for such review. A regulatory guide on
    management review of nuclear material control and accounting programs
    (now in preparation) will provide guidance on the conduct of such
    reviews.
    11.2.1.1 Report. Indicate, by position title, the individuals
    who receive reports of the results of the management review.
    11.2.1.2 Action. Discuss the procedures used to assure that
    the recommendations are reviewed by management and appropriate action is
    taken.
    11.2.2 Measurement Controls
    Describe the plan of action to be followed when measurement
    performance exceeds established control limits. By position titles
    listed in Section 3.1.1, indicate assignments of responsibilities and
    authorities for action in response to out-of-control indications. The
    description should include identification of specific actions to be
    taken, organizational positions to be notified, circumstances under
    which site management and the AEC would be notified, and the reports to
    be made.
    11.2.3 Shipper-Receiver Differences
    Describe the plan of action to be followed when a significant
    shipper-receiver difference has been discovered for an individual
    shipment, a series of shipments, or an individual lot or container. The
    description should include identification, by position titles, of
    individuals responsible for action, individuals to be notified, specific
    actions to be taken, and reports to be made. Refer to Sections 10.1.2
    and 10.1.3, as appropriate.
    11.2.4 Material Balance Discrepancies
    Describe the plan of action to be followed when MUF exceeds LEMUF,
    including identification, by position title, of individuals responsible
    for action, individuals to be notified, specific actions to be taken,
    and reports to be made. Refer to Chapter 7, as appropriate.
    11.2.5 Item Discrepancies
    Describe the plan of action to be followed when an item or
    container of special nuclear material is reported to be missing,
    including identification, by position title, of individuals responsible
    for action, individuals to be notified, specific action to be taken, and
    reports to be made.
    CHAPTER 12PRODUCTION DOCUMENTATION AND VERIFICATION
    (Supplement for Uranium Enrichment Facilities) An application for a license to possess special nuclear material
    at a uranium enrichment facility licensed pursuant to 10 CFR Part 50(*)
    should be supplemented with the additional information identified in
    this chapter. Uranium enrichment facilities are designed specifically to
    produce special nuclear material. Consequently, in addition to
    implementing measures to assure that special nuclear material in his
    possession is not stolen, a licensee operating a uranium enrichment
    facility should also provide information which provides assurance that
    measures can be implemented to protect against surreptitious production
    of special nuclear material. Such assurance requires a material balance
    on the material in process and an accounting for the separative work,
    supplemented by appropriate confirmatory data.
    12.1 Material Balances For Material In Process
    In this section, describe the procedures that will be used for
    measuring, calculating, and statistically analyzing the amount of
    material in process on a monthly basis.
    12.1.1 In-Process Inventory
    List the nominal design amounts of uranium and U-235 in process
    equipment, connecting piping, and support equipment such as traps, pump
    oils, etc. List the amounts separately for each type and size of
    equipment. Describe how these quantities will be measured at inventory
    time. Refer to the flow diagrams provided in Appendix A, as
    appropriate.
    12.1.2 Feed and Withdrawal Cutoff
    Describe the procedures that will be used to measure and record
    the quantities of uranium and U-235 at the time of inventory cutoff in
    each feed and withdrawal cylinder connected to the cascade.
    12.1.3 Calculation of Material Balance
    Affirm that a material balance for the in-process material shall
    be calculated monthly. (Note that the inventory and material balance
    requirements for the total plant, which are contained in paragraph
    70.51(e) of 10 CFR Part 70, must also be met.)12.1.4 Analysis of Data on Material Unaccounted For
    Describe the method that will be used for analysis of the
    historical, cumulative, and current data on the uranium and U-235
    material unaccounted for (MUF) in the process to demonstrate normal (as
    licensed) operation. Explain how the short-term perturbations caused by
    the periodic recovery of material from equipment will be treated in the
    analysis.
    ----------
    (*) Part 52, currently in preparation, would, if adopted, contain
    requirements specific for the licensing of uranium enrichment
    facilities.
    ----------
    12.2 Separative Work
    In this section, describe the procedures that will be used for
    calculating the separative work done by the process.
    12.2.1 Value Function
    Define mathematically the value function that will be used for
    calculation of separative work, and state the reason(s) for the
    selection of the value function chosen.
    12.2.2 Calculation of Separative Work
    Describe the procedures and records that will be used to account
    for separative work, including that in the material unaccounted for
    calculated from the in-process material balances done in accordance with
    Section 12.1.
    12.3 Parametric Correlations
    In this section, indicate the provisions that will be made for
    acquiring the prescribed confirmatory data.
    12.3.1 Consumption of Electricity by Process
    Describe the means that will be used for measuring electrical
    consumption by the process. Include a schematic description of the
    electrical distribution in the process building(s), with voltages,
    showing the points where electrical consumption of the process is
    measured. Estimate the quantity of electricity included in this
    measurement that is not used in the process (e.g., that used in
    lighting, ventilation, etc.)12.3.2 Power Utilization Index
    Estimate the power utilization index (PUI), defined as separative
    work units/megawatt-day. Describe the basis for that estimate and the
    procedures planned to verify the estimate. Affirm that the PUI will be
    determined weekly during initial operation of the plant.
    12.3.3 Time-Line Analysis
    Describe the procedures that will be used to identify and record
    the time when feed is commenced and terminated from each feed cylinder
    and when withdrawals are commenced and terminated in each product and
    tails cylinder. Also, describe the procedures that will be used to
    identify the feed or withdrawal point for each such cylinder.
    12.3.4 Measurement of Minor Isotopes
    Describe the provisions that will be made for measuring and
    recording the content of minor isotopes (U-234 and U-236) for each feed
    and product or tails withdrawal.
    12.4 Records and Evaluation
    In this section, describe the records that will be kept in
    connection with the measurements and calculations provided for in this
    chapter and the use to be made by management of such data.
    12.4.1 Records Retention
    Indicate the length of time that records discussed in this chapter
    will be retained.
    12.4.2 Records Availability
    Describe the procedures that will be used to ensure that records
    discussed in this chapter will be available for inspection by Commission
    inspectors.
    12.4.3 Control Limits
    Describe the procedures that will be used to set control limits on
    current in-process material unaccounted for (uranium and U-235),
    cumulative material unaccounted for, and power utilization index, and
    the management action that will be taken when any control limit is
    exceeded.
    APPENDIX ASITE DESCRIPTION
    General Description
    In this section, provide a general description and physical layout
    of the site and its operations. The various plants and support
    functions should be identified. Provide drawings and narrative as
    necessary to convey the overall involvement with special nuclear
    material. Explain the typical distribution of special nuclear material
    within the site, taking into consideration the various operations and
    storage areas.
    Plant Operations
    In this section, provide a detailed description of plant
    operations, manufacturing processes, chemical flowsheets, and material
    flows. Present the description of each of the processes in narrative
    and flow diagram form. Describe each process in terms of feed materials,
    intermediate and final products, recycle, scrap, and waste materials.
    Identify gaseous, liquid, and solid effluents which could but do not
    normally contain special nuclear material. Identify and describe points
    in each of the processes where chemical and physical changes or blending
    of enrichment categories of special nuclear material occur.
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